This Privacy Policy explains how ÉLAN PRIVÉ collects, uses, stores and protects personal data in connection with the use of the platform. Personal data is processed in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection law.
The controller responsible for personal data processed through ÉLAN PRIVÉ is the entity that operates and administers the platform, identified below.
Controller: CodeLab - Digital Solutions
Tax identification number: PT233127690
Registered office or professional address: Rua Dona Maria II 154
Privacy contact: marketingstudysolutuons@gmail.com
This Policy applies to personal data processed through ÉLAN PRIVÉ in relation to visitors, Members, Providers and persons who contact the platform through the available channels.
It covers processing required for accounts, profiles, services, requests, messages, subscriptions, payments, Support, moderation, security and platform administration.
The categories of personal data processed depend on how each person uses the platform and the information they choose to provide.
Account data: name, email address, internal identifiers, account type, account status and securely stored credentials, including a protected representation of the password where applicable.
Provider data: public name or pseudonym, headline, biography, location, languages, availability, photographs, displayed services and other information submitted to create and manage a profile.
Platform activity data: requests, internal messages, notifications, interaction statuses and information required to manage the features used.
Support and moderation data: name, email address, subject, message, communications submitted and information associated with support requests, reports, incidents and administrative or moderation decisions.
Technical and security data: technical identifiers, IP address, session information, security logs and other information strictly necessary to protect, diagnose and operate the platform may be processed.
Providers supply additional information to create and maintain their profile. Some of that information is expressly intended to be displayed to other users through public or discovery areas of the platform.
Providers should carefully consider which optional information they make publicly available and must not publish personal data relating to third parties without an appropriate legal basis or authorisation.
ÉLAN PRIVÉ may process information concerning profile status, approval, moderation and subscription in order to manage Provider eligibility and visibility on the platform.
Photographs submitted by users may constitute personal data where a person can be identified. The person uploading an image must have the rights and permissions necessary to use and make that image available.
ÉLAN PRIVÉ uses photographs for profile and content presentation, platform management and moderation. A photograph is not treated merely by reason of being a photograph as biometric data used for unique identification unless it is subject to specific technical processing for that purpose.
When Members and Providers use internal request or communication mechanisms, the platform processes the information required to deliver, display, organise and manage those interactions.
Support communications and information relating to reports or incidents may be reviewed by authorised persons where necessary to provide assistance, protect users, investigate abuse, moderate content or comply with legal obligations.
When a Provider purchases a paid subscription, data required to create, identify and manage the subscription and its payment status is processed.
Complete card details entered directly into the payment provider infrastructure are not stored by ÉLAN PRIVÉ. The platform may retain external customer, subscription or transaction identifiers and status information required to operate the subscription.
Personal data is processed only for specified purposes compatible with use of the platform.
Account management: creating, authenticating, administering and protecting Member and Provider accounts.
Service provision: displaying profiles and services, enabling discovery, requests, messages, notifications, moderation and other platform features.
Subscriptions and payments: initiating, administering and confirming Provider subscriptions and managing their status.
Security and abuse prevention: protecting accounts, preventing fraud, investigating incidents, maintaining platform integrity and enforcing the Terms.
Support: responding to questions, requests, complaints and communications submitted by users.
Legal compliance: retaining or disclosing information where necessary to comply with legal obligations, establish or defend rights and respond to lawful requests from competent authorities.
The legal basis used depends on the specific purpose of the processing.
Performance of a contract or pre-contractual steps: used where processing is necessary to create and manage an account, provide requested features or administer a purchased subscription.
Legal obligation: used where certain information must be processed or retained in order to comply with legal obligations applicable to the controller.
Legitimate interests: may support processing required for security, fraud prevention, platform protection, moderation, defence of rights and service reliability, after considering the rights and reasonable expectations of data subjects.
Consent: used where the law requires consent or where a particular optional feature or processing activity is expressly based on such permission. Consent may be withdrawn in accordance with applicable law.
Certain information entered by a Provider is intended for presentation on their profile and may become visible to visitors or platform users according to the available features, approval status and applicable visibility rules.
Information intended solely for account administration, security, payments or internal operation is not displayed as part of a public profile unless the user has themselves chosen to publish it through a field intended for that purpose.
Personal data may be processed by technology providers supplying services required to operate ÉLAN PRIVÉ, such as hosting, infrastructure, payments, security or other technical functions, within the limits necessary to provide those services.
Information may also be disclosed where required by law, a court order or a legally valid request from a competent authority, or where necessary to establish, exercise or defend legal rights.
Provider subscription payments may be processed through Stripe. During payment, certain information is sent directly or otherwise made available to Stripe for transaction processing, fraud prevention and compliance with its legal obligations.
Stripe processes certain information according to its own responsibilities and privacy documentation. ÉLAN PRIVÉ receives and retains only the information required to identify and administer the subscription and its status according to the technical implementation used.
Platform data is processed through the hosting infrastructure and technology services used by ÉLAN PRIVÉ. The controller seeks to select providers offering appropriate data protection and security safeguards and to put in place the arrangements required by applicable law.
Some technology providers may process or make data accessible from countries outside the European Economic Area. Where an international transfer of personal data occurs, mechanisms recognised by applicable data protection law will be used as appropriate.
These mechanisms may include European Commission adequacy decisions or appropriate safeguards such as Standard Contractual Clauses, together with supplementary measures where required.
Personal data is retained for as long as necessary for the purposes for which it was collected and subsequently for periods required to comply with legal obligations, resolve disputes, prevent fraud and establish, exercise or defend legal rights.
Specific periods may vary according to the category of information, duration of the account or subscription, applicable legal obligations, security requirements and statutory limitation periods. When information is no longer required, it will be deleted or anonymised in accordance with applicable procedures.
ÉLAN PRIVÉ implements technical and organisational measures intended to protect personal data against unauthorised access, alteration, disclosure, loss or improper destruction, taking into account the nature of the information and the risks associated with processing.
No online service can guarantee absolute security. Users should protect their credentials, use appropriate passwords and promptly report any suspected unauthorised access.
ÉLAN PRIVÉ uses only cookies or technical mechanisms that are strictly necessary for the operation of the platform, including session management, authentication, security and maintenance of essential functionality.
These mechanisms are not used for behavioural advertising or marketing profiling. If the platform introduces non-essential cookies or similar technologies in the future, this Policy will be updated and an appropriate information and consent mechanism will be implemented where legally required.
Under applicable data protection law, individuals may exercise the rights available to them in relation to their personal data.
These rights may include access, rectification of inaccurate information, erasure, restriction of processing, objection, data portability and the right not to be subject to certain decisions based solely on automated processing that produce legal or similarly significant effects, where applicable.
The exercise of particular rights is subject to the conditions and exceptions established by law. ÉLAN PRIVÉ may request information reasonably necessary to verify the identity of the person making a request.
Where processing is based on consent, consent may be withdrawn at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal and does not affect processing based on another valid legal basis.
Individuals may contact ÉLAN PRIVÉ regarding any matter concerning the processing of their personal data or the exercise of their rights.
Without prejudice to other administrative or judicial remedies, data subjects have the right to lodge a complaint with a competent supervisory authority. In Portugal, the national supervisory authority is the Comissão Nacional de Proteção de Dados — CNPD.
ÉLAN PRIVÉ is intended exclusively for persons aged 18 or over. The platform does not intend to knowingly collect personal data through accounts belonging to minors. Such situations may be reported through Support for review and appropriate action.
In the platform’s current configuration, ÉLAN PRIVÉ does not intend to make decisions based solely on automated processing that produce legal effects concerning a user or similarly significantly affect them. If this changes, the information required by applicable law will be provided.
This Policy may be updated as a result of legal, regulatory, technical or functional changes. Where changes are relevant to the processing of personal data, appropriate steps will be taken to inform users. The current version will remain available on this page.
Requests concerning personal data, exercise of rights or questions about this Policy may be submitted through Support or to the privacy address identified at the beginning of this Policy.
Version 1.0 — Last updated: 26 August 2026.